ML20199J655

Forwards NRC Positions on Requested Exemptions for AP600 Design

ML20199J655
Person / Time
Site:	05200003
Issue date:	01/30/1998
From:	Quay T NRC (Affiliation Not Assigned)
To:	Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 9802060003
Download: ML20199J655 (5)

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January 30.l1998 A

,i Mr. Nicholas J, Liparuto, '."nge'

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Nuclear Safety and Regulatory Analysis _

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Nuclear and Advanced Technology Division 1

Westinghouse Electric Corporation -

l P.O. Box 355 f'

Pittsburgh, PA.15230

SUBJECT:

EXEMPTIONS FOR AP600 DESIGN

Dear Mr. Liparulo:

in a letter dated September 12,1997 iDCP/NRC1029), Westinghouse requested exemptions from certain regulations that are set forth in Title 10 of the Code of Federal Regulations (r.FR). The Nuclear Regulatory Commission stafra positions on the requested

. exemptions are enclosed,. The enclosure follows the format used by Westinghouse in its -

request. The Standard. Safety Analysis Report for the AP600 design must be revised to be consistent with the approved exemption requests, in' addition, because the AP600 design does not have en auxiliary (or emergency) feedwater system, Westinghouse should subrait a request for an exemption from 10 CFR 50.62(c)(1). if you have any questions regarding this matter,

. please contact Jerry Wilson at (301) 415 3145.

. Sincerely, original sig'ned by: Jerry N.' Wilson Theodore R. Quay, Director Standardization Project Directorste -

Division of Reactor Program Management -

Office of Nucleer Reactor Regulation Docket No.52-003

Enclosure:

As stated:

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DISTRIBUTION:

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DOCUMENT NAME: A:\\EXMPTION.JNW -

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OFFICIAL RECORD COPY :

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- Mr. Nicholas J. Liparuto Docket No.52-003

- Westinghouse El@ctric Corporation AP600 cc:

Mr. B. A. McIntyre Mr. Russ Bell-Advanced Plant Safety & Licensing Senior Project Manager, Programs

. Westinghouse Flectric Corporation Nuclear Energy institute Energy Systems Business Unit -

1776 i Street, NW.

P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006 3706 Ms. Cindy L. Haag Ms. Lyrin Connor Advanced Plant Safety & Licensing Doc Searen Associates Westinghouse Electric Corporation Post Office Box 34 Energy Systems Business Unit Cabin John, MD 20818 Box 355 -

Pittsburgh, PA 15230 Dr. Craig D. Sawyer, Manager Advanced Reactor Programs Mr. Storiing Franks GE Nuclear Energy U.S. Department of Energy 175 Curtner Avenue, MC-754 NE 50 San Jose, CA 95125 19901 Germantown Road

- Germantown, MD 20874 Mr. Robert H. Buchholz GE Nuclear Energy Mr. Frank A. Ross 175 Curtner Avenue, MC 781 0

- U.S. Department of Energy, NE-42 San Jose, CA 95125 Office of LWR Safety and Technology 19901 Germantown Road Barton Z. Cowan, Esq.

Germantown, MD 20874 Eckert Seamans Cherin & Mellott 600 Grant Street 42nd Floor o

Mr. Charles Thompson, Nuclear Engineer Pittsburgh, PA 15219 AP600 Certification NE 50 Mr. Ed Rodwell, Manager 19901 Germantown Roao PWR Design Certification Germantown, MD 20874 Electric Power Research Institute 3412 Hillview Avenue Mr. Robert Maiers, P.E.

Palo Alto, CA 94303

- Pennsylvania Department of Environmental Pmtection Bureau of Radiation Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 -

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DISTRIE JTION: Letter to Mr. Nicholas J. Lloaruto. Dated:

January 30. 1998 Docket le -

PUBLIC PDST R/F JRoe DMatthews TQuay TKenyon WHuffman JSebrosky DScaletti JNWilson ACRS (ii)

WDean,0-16 E15 JMoore,015 B1B RWelsman,015 B18 4

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EXEMPTION REQUEST FOR AP600

--1, Exemption from dedicated containment penetration requirement.

Westinghouse requested an exemption from 10 CFR 50.34(f)(3)(iv), which requires one or more containment penetrations that are equivalent in size to a sirgio 3 foot diameter

- opening The AP600 design has two containment penetrrtions that will satisfy this requirement.. Therefore, this request for an exemption is not needed and is, hereby, denied.

2. Exemption from requirement for two physically independent circuits.

Westinghouse re: quested an exemption from GDC 17, " Electrical Power Sfstems," which requires two physically independent circuits from the transmission network to the onsite electile distribution system. The NRC staff agrees that the special circumstances set forth in 10 CFR 50.12(a)(2)(li) exist in the AP603 design because Westinghouse has described an acceptable attemative approach to accomplish the necessary safety functions that does not rely on power from the offsite system and, therefore, accomplishes the intent of GDC 17.

The NRC's acceptance of this exemption request will be documented in its Final Safety Evaluation Report (FSER) for the AP600 design.

3. Exemption 5m ASME Code, Section lil, for Class C gas storage vessels.

Westinghouse requested an exemption from 10 CFR 50.55a(e), which requires that components that are classified as Quality Group C must meet the requirements for Class 3 components in ASME Code, Section lil. Westinghouse has proposed to use attemative crKeria in the ASME Code for the air storage tanks that are constructed of forged, seamless pipe, with no welds. The NRC will document its evaluation of Westinghouse's proposed

- attemative, pursuant to 10 CFR 50.55a(a)(3). In its FSER for C4 /sP600 design. Therefore, because this request will be evaluated pursuant to the proposed hitemative provision of 10 CFR 50.55a, an exemption is not needed and is, hereby, denied.

4,- Exemption from the operating basis earthquake design requirement.

Westinghouse reques.ed an exemption from the operating basis earthquake design requirement in 10 CFR Part 100, Appendix A. Because an application for design certification must comply with the Commission's regulations that are applicable and in effect at the time that the certification is issued, the earthquake englneering criteria in Appendix S to 1G CFR

Part 50 are applicable to the AP600 design. Therefore, because the AP600 design meets the design requirements in Appendix S, this request for an exemption is not needed and is, hereby, denied. The NRC will document compliance wi'h Appendix S in its FSER for the AP600 design.

5. Exemption from ASME OM Code for Inservice testing requirements.

. Westinghouse requested an exemption from 10 CFR 50.55a, which requires that the OMa-1988 Addenda to the OM-1987 Edition be used for the requirements for inservice testing of active safety related valves. Westinghouse requested that the 1990 OM Code be used because it represents a significant restructuring of the format of the requirements. The NRC staff has r.omp%ted its review of the inservice testing requirements for the AP600 design and concluded that the commitments in the AP600 SSAR, Section 3.g.6, meet the

! requirements set forth in the 1987 Edition. Therefore, this request for an exemption is not needed and is, hereby, denied. The NRC will document compliance with the 1907 Edition in y

'its FSER for the AP600 design.

Enclosure

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6. Exemption from ASME OM Code for inservice testing frequency.

i Westirmhouse requested an exemption from 10 CFR 50.55a (ASME/ ANSI OMa 1988 Code, Part 10), which requires a testing frequency of three months for the ADS stage 1,2, and 3 valves. In Revision 17 of the AP600 SSAR, Section 3.9.6.3, Westinghouse withdrew this j

exemption request and committed to test the ADS valves at the cold shuMown frequency pursuant to Par 110 of the OM Code. The NRC staff concludes that this commitment meets the upplicable requirements in 10 CFR 50.55a and will document its position in the AP600 FSER. Therefore, this exemption is not needed.

7. Deleted by Westinghouse.

8. Exemption from the requirement for criticality monitoring of new fuel in storage.

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Westinghouse requested an exemption from 10 CFR 70.24, which requires a criticality monitoing system and radiation detectors in any area of the plant where more than specified i

amounts of special nuclear material may be handled, used, or stored. The monitoring system and detectors ate not required when the materialis handled or stored under water shielding or is being transported when packaged in accordance with 10 CFR Part 71. This requirement L'

does not affect the AP600 design and an exemption is not required. Therefore, your request for an exemption is, hereby, denied. However, you should be aware ' hat the criticality accident requirements of 10 CFR 70.24, as they pertain to nudear power plants, are being revised. A direct final rule was issued on December 3,1997, and is expected to become effective on February 17,1998. This rule establishes altemative criticality accident requirements for nuclear power plants in a new secuon,10 CFR 50.68, Ti.a NRC staff, as part of its review of an application that references the AP600 design, will ensure that the applicant meets the applicable requirements of 10 CFR 50.68 or 70.24.

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